Mcnaughton v. Charleston Charter School For Math And Science Inc.

Facts

D hired P to teach 6th, 7th, and 8th-grade art, along with the yearbook class. D knew that P was participating in the ACE program and that her completion of the program was contingent upon her fulfillment of further requirements, including the completion of an induction teaching year. P signed an employment agreement, in which P agreed to be a full-time teacher at D for the school year 2010-2011. The agreement was 'contingent on funding and enrollment.' D would pay P a yearly salary of $34,040. P received positive feedback from students and parents. According to the principal, P was a talented art teacher, especially when it came to designing cross-curricular lessons. On December 1, 2010-in the middle of the school year-the D informed P that D was terminating her employment. D needed to use the funds designated for P's salary to hire and pay a new math teacher because some of the students had performed poorly on a recent math achievement test. When P was terminated, there was funding available to pay P's salary, but that the funding was instead used to hire and pay the new math teacher. P invoked D's grievance and termination policy and began the grievance procedure. D told her that D had the legal right to move funding around as it chose and that because P was an at-will employee, the principal 'could do whatever she wanted.' The chairwoman of the board of D notified P that she had no 'standing' to continue the grievance procedure.  P sued D in part for breach of contract. D wrote a letter of reference, but P was only able to find a job teaching two days a week, which did not grant her enough teaching hours to remain in the PACE program. P applied for jobs in graphic design as well as entry-level jobs but was unsuccessful. P also applied for and received unemployment benefits. P testified she was forced to purchase COBRA health insurance for $250 per month, withdraw the available funds from her state retirement fund, and deferred her student loans, which resulted in $2,500 additional interest. P testified that she was unable to refinance her home and that her bank foreclosed upon her mortgage. The jury returned a verdict of $20,623 in actual damages and $74,112 in special damages. D moved for JNOV and a new trial. Both were denied. The court also awarded attorney fee. D appealed, and the case was certified to the South Carolina Supreme Court. (The Blum 4^th Casebook only looks at the special damages part of the judgment). 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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